B. Considerations of the Court 172. Article 22(1) of the Convention recognizes the right to freedom of movement and residence. In this regard, the Court has established in other cases that this article also protects the right not to be forcibly displaced within a State Party.258 173. In this regard, the Court has considered that the United Nations Guiding Principles on Internal Displacement259 are particularly relevant to determine the content and scope of Article 22 of the American Convention.260 The principles state that “internally displaced persons are persons or groups of persons who have been forced or obliged to flee or to leave their homes or places of habitual residence, in particular as a result of or in order to avoid the effects of armed conflict, situations of generalized violence [or] violations of human rights […] and who have not crossed an internationally recognized State border.261 174. This Court has established that, given the complexity of the phenomenon of internal displacement and the broad range of human rights that it effects or that are put at risk, and based on the circumstances of special vulnerability and defenselessness in which the displaced generally find themselves, their situation can be understood as a de facto condition of lack of protection.262 In keeping with the American Convention, this situation obliges the States to adopt positive measures to reverse the effects of the said condition of weakness, vulnerability and defenselessness, including vis-à-vis the actions and practices of private individuals.263 175. Thus, this Court has indicated that the right to freedom of movement and residence can be violated by de facto restrictions, if the State has not established the conditions or provided the means to allow that right to be exercised;264 for example, when a person is a 258 Cf. Case of the Mapiripán Massacre v. Colombia. Merits, reparations and costs. Judgment of September 15, 2005. Series C No. 134, para. 188, and Case of Chitay Nech et al. v. Guatemala, supra, para. 139. 259 Cf. Commission on Human Rights, United Nations Guiding Principles on Internal Displacement, E/CN.4/1998/53/Add.2 of 11 February 1998, p. 5. Annex. Introduction: scope and purpose. (No. 2). Available at: http://daccess-dds-ny.un.org/doc/UNDOC/GEN/G98/104/93/PDF/G9810493.pdf?OpenElement. These principles have been recognized by the international community. See also, United Nations, General Assembly, Protection of and assistance to internally displaced persons A/RES/64/162, of 17 March 2010, p.1. Available at: http://www.un.org/ga/search/view_doc.asp?symbol=A/RES/64/162. See also, Council of Europe, Committee of Ministers, Recommendation Rec (2006)6 to member states on internally displaced persons, 5 April 2006. Available at:https://wcd.coe.int/ViewDoc.jsp?id=987573&BackColorInternet=9999CC&BackColorIntranet=FFBB55&BackColo rLogged=FFAC75; African Union, Convention for the Protection and Assistance of Internally Displaced Persons in Africa (Kampala Convention), 23 October 2009, article 1, K). Available at: http://www.unhcr.org/4ae9bede9.html; Human Rights Council, Report presented by the Representative of the Secretary-General on the human rights of internally displaced persons, Walter Kalin. A/HRC/13/21/Add.3, p.4. II.4. Available at: http://www2.ohchr.org/ english/bodies/hrcouncil/docs/13session/A-HRC-13-21-Add.3.pdf. 260 Cf. Case of the Moiwana Community v. Suriname Preliminary objections, merits, reparations and costs. Judgment of June 15, 2005. Series C No. 124, para. 111, and Case of Chitay Nech et al. v. Guatemala, supra, para. 140. 261 United Nations Guiding Principles on Internal Displacement, supra, para. 2. In this regard, the General Assembly of the Organization of American States has recommended that the States use the Guiding Principles as a basis for developing their policies, and even that they incorporate them into their domestic law, in order to promote implementation. Cf. AG/RES. 2508 (XXXIX-O/09) “Internally Displaced Persons,” approved at the fourth plenary session held on June 4, 2009, operative paragraph 2 (Available at: www.oas.org/dil/esp/AG-RES_2508-2009.doc). 262 Cf. Case of the Mapiripán Massacre v. Colombia, supra, para. 177, and Case of Chitay Nech et al. v. Guatemala, para. 141. 263 Cf. Case of the Mapiripán Massacre v. Colombia, supra, para. 179, and Case of Chitay Nech et al. v. Guatemala, supra, para. 141. 264 Cf. Case of the Moiwana Community v. Suriname, supra, paras. 119 and 120, and Case of Chitay Nech et al. v. Guatemala, supra, para. 142. 66